The trial court erred by entering a default judgment against defendants because plaintiff did not provide notice of a request for entry of a default. Further, in seeking to have the default judgment set aside, the court rule requiring defendants to show they had a meritorious defense is unenforceable as a matter of due process, given the lack of notice.

The trial court incorrectly considered defendant’s hands as “dangerous weapons” in scoring Offense Variables 1 and 2 for sentencing defendant following his conviction for assault with intent to commit sexual penetration.

Evidence that trained dogs alerted to the scent of decomposing human remains in a car’s trunk was properly admitted under MRE 702 at defendant’s trial for first-degree murder and child abuse. Further, the evidence was relevant under MRE 403.

The trial court correctly determined that a report defendants prepared concerning a sewer system project was prepared in anticipation of litigation, however, further proceedings are required on remand to determine whether the report is subject to the attorney work-product privilege.